ITAT Delhi ruling provides guidance for ascertaining arm’s length price of an international transaction under TNMM

In the case of:- IL Jin Electronics (I) Pvt. Ltd. Vs. Asst. Commissioner of Income Tax [ITA No. 438/Del/2008] Facts of the Case Established in September, 2001, IL Jin Electronics (I) Pvt. Ltd. (IL Jin/ Taxpayer) is engaged in the business of manufacturing & selling printed circuit boards for consumer durables. It commenced commercial production in January, 2002. During FY 2002-03, for its operations, the Taxpayer entered into various international transactions (See Note 1 below)  with its AEs, with the bulk of international transactions being that of purchase of raw material. Out of th...